OECD

Organisation for Economic and Commercial Development.

BEPS, CCCTB, EU/EEA, OECD

(Catholic University in Italy; Maisto & Associati)/ /Leave a comment

This contribution lays down a general plan for what the EU should do in order to attain a harmonized set of norms regulating the allocation of taxing rights among Member States and in the relation between those States and third countries, which would benefit both Member States and their taxpayers by eliminating several instances of…

BEPS, OECD, Permanent Establishments, Tax Treaties, VAT

(Temple Tax Chambers; King’s College London)/ /Leave a comment

Google’s international corporate structure and operating model has featured significantly in the political and legal debate about the taxation of multinational companies, particularly in the technology sector. Although presented in anonymous form, “Rco Group”, engaged in internet search and advertising services described in the OECD BEPS Action 1, Addressing the Tax Challenges of the Digital…

BEPS, OECD

(Mariz de Oliveira e Siqueira Campos Advogados)/ /Leave a comment

On 22 June 2017, the OECD released for public comment the revised discussion draft on the application of the profit split method, which intends to continue the work developed in the OECD Transfer Pricing Guidelines and, in more details, in the BEPS Actions 8-10, whose motto aims to assure that transfer pricing outcomes are in…

BEPS, MAPs and APAs, OECD, Permanent Establishments, Tax Policy, Tax Treaties, Transfer Pricing

(Tax Lawyer)/ /Leave a comment

On June 7, 2017, India joined more than 65 countries in signing the OECD’s Multilateral Instrument to implement tax treaty-related base erosion and profit shifting (BEPS) recommendations. The Instrument – developed under Action 15 of the BEPS project – seeks to transpose BEPS recommendations into over a thousand tax treaties in a “synchronized and efficient…

EU/EEA, OECD, Tax Policy, Transfer Pricing

(Maastricht University )/ /Leave a comment

On 21 June 2017, the European Commission released its Proposal on transparency rules for tax intermediaries. It primarily seeks to address concerns raised by the ECOFIN Council and the European Parliament in trying to investigate and tackle the role of intermediaries in tax evasion and tax avoidance schemes of multinational companies. New rules impose an…

EU/EEA, OECD, State Aid, Transfer Pricing

(Maisto e Associati)/ /Leave a comment

An analysis from a State Aid perspective. This contribution focuses on the profit split methodology in light of current EU Commission’s investigations in the area of tax rulings and transfer pricing[1]. Prior to my points, I shall make some brief preliminary comments to set the scene. According to the EU Commission a tax ruling confers…

BEPS, Intangibles, OECD

(International tax professional)/ /2 Comments

On 23 May the OECD published a Public Discussion Draft on Implementation Guidance on Hard-to-Value intangibles (HTVIs).  Comments are due by 30 June 2017, so hurry. 1.    Introduction All guidance by the CFA and the opportunity to comment is appreciated, especially on a major topic like intangibles.  That being said, I think that this paper…

FATCA, OECD

(Texas A&M University Law)/ /1 Comment

FATCA: GIINs and LEIs Musings of Professor William Byrnes with the tremendous brain power of Haydon Perryman Firstly, a loud shout out to Haydon Perryman who crunches the IRS GIIN list into workable data.  His research is at the forefront of FATCA and CRS intelligence and the only available for analysis of FATCA.  Now unto some numbers. As…

Arbitration, BEPS, MAPs and APAs, OECD, Tax Avoidance, Tax Policy, Tax Treaties

(Temple Tax Chambers; King’s College London)/ /2 Comments

There is no doubt that 7 June 2017 is a day that will be a milestone in the history of international tax law. Signature of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“MLI”) at a high-profile ceremony at the OECD in Paris by 68 ministers and…

Arbitration, BEPS, EU/EEA, MAPs and APAs, OECD, Tax Policy, United Nations

(TRIBUTE Foundation for improvement of international tax dispute resolution)/ /Leave a comment

A world of tax without disputes is an illusion. It is just as much an illusion as a world without tax. Tax and disputes come together inseparably. Disputes is not something to be ashamed of – I say this in particular to authorities. Nor – and it this meant more for taxpayers –  to be…

BEPS, Hybrids, OECD, Permanent Establishments, Tax Policy, Tax Treaties

, , (EY Mexico)/ /Leave a comment

As a member of the Organization for Economic Co-operation and Development (“OECD”) Mexico[1] has been actively involved in the design and development of the Base Erosion and Profit Shifting (BEPS) Project and began implementing many of the recommended actions in 2014, even before the final BEPS reports were finalized in 2015. The execution and implementation…

OECD, Permanent Establishments

(Tax Lawyer)/ /1 Comment

Consider this. Formula One World Championship Limited UK (Formula One) entered into a Race Promotion Contract (RPC) with Jaypee Sports International Limited (Jaypee), an Indian entity, under which Jaypee was granted the right to host, stage, and promote a motor racing event in India. Buddh International Racing Circuit located in the Indian state of Uttar…

BEPS, OECD, Permanent Establishments, Tax Treaties

(Temple Tax Chambers; King’s College London)/ /1 Comment

On 24 April 2017 the Indian Supreme Court held that Formula One World Championship Ltd, the holder of the commercial rights to the Formula One Grand Prix, had a permanent establishment in India at the Buddh International Circuit where the event was held in 2011, 2012 and 2013. The Supreme Court concluded that the UK…